
Essay
The Last SIFI: The Unwise and Illegal Deregulation of Prudential Financial
by Jeremy C. Kress*
On October 16, federal regulators released Prudential Financial from enhanced government oversight. This Essay contends that in removing Prudential’s “systemically important” label, regulators (1) violated their established procedural rules, (2) relied on misleading quantitative analyses, and (3) failed to consider a mandatory statutory factor. This Essay thus urges litigation and Congressional oversight challenging the rescission of Prudential’s “systemically important” status.